Interim Management Leadership Restores Agency’s Compliance After Failed ZPIC Audits
A home care agency affiliated with a large health system in Florida.
The health system was unable to successfully fill several key leadership roles within their home care agency after a loss of leadership. Eleven critical positions were vacant within the clinical, quality assurance, and finance departments. As a result, leadership, strategy, quality performance, and compliance profoundly suffered. The agency ultimately failed a Zone Program Integrity Contractor (ZPIC) audit leading to a continual focused review by Medicare, which required an immediate billing shutdown and additional documentation requests on all episodes. Following the failure of the ZPIC audit, two separate mock surveys conducted onsite indicated no improvement in any of the critical areas. The home care agency needed significant realignment before the surveyors came back onsite, or the agency was in severe jeopardy of closing.
The health system engaged McBee on interim management, compliance, and turnaround to restore the organization. McBee provided a full-time interim CEO to improve corporate leadership relations, organizational stability, and establish a functional and positive environment. The interim CEO developed requirements for incumbents and filled team-lead vacancies with candidates that possessed both technical and leadership skills, as well as possessing a high correlation to the health system values. To rebuild a collaborative supportive home care team, McBee stabilized operations by establishing common goals, performance standards, and team accountability for achieving those goals.
To assist in this effort, McBee deployed an interim clinical manager to establish clinical documentation best practices and improvements, reduce the backlog of OASIS submissions, conduct regular chart audits, and provide educational sessions to ensure survey readiness. In addition, an interim quality assurance and performance improvement (QAPI) manager was brought on to lead the organization’s survey readiness through regularly scheduled audits to build compliance, establish quality QAPI data measurements, and develop a QAPI structure.
Further, the engagement team customized and implemented McBee’s Pre-bill Audit solution where each episode was uploaded prior to billing. This allowed all claim requirements for billing and all episodes that were not approved for billing to be assessed in one process to track and improve compliance deficiencies. Through this, McBee also identified errors in clinical documentation so they could be corrected to mitigate risk. These errors included lack of documentation and timely filing of OASIS assessment to CMS.
To restart cash flow, McBee corrected and re-billed more than 300 episodes and removed the ZPIC payment shutdown status.
Overall, the compliance rate more than doubled in less than a year.
After the six-month survey preparation period, the organization passed the
Pre-bill clinical review process enabled the agency to resume billing in less than one year, recover over $1.7M in payments by Medicare, and allow more than 70% of episodes to be billed without restriction.
Identified and established 80% of the new leadership in 6 months.
Restored leadership stability and built collaborative working relationships among departments.
Provided ongoing support of clinical documentation efforts through tracking and training clinicians with McBee’s OASIS Match reporting program.
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